About This Map

This interactive chart is intended to be a concise and comprehensible presentation of the tax regimes which govern the use of holding companies in 15 European jurisdictions, taking care to reflect upon the new reality resulting from the O.E.C.D. B.E.P.S. Project and several European Commission initiatives intended to eliminate cross-border tax planning arrangements. For more detailed information regarding a particular country, please look to the relevant chapter in the full special edition of Insights.

Click a country to view its tax treatment.

Tax Rate (Percent)

Regular Withholding Tax Rate (Percent)

Regular Rate (Percent)

Number of Treaty Countries

Tax Rate (Percent)

Both Fully Exempt

Capital Gains Fully Exempt

Neither Fully Exempt

Fully Exempt

Partially Exempt

Relief Available

No Relief Available

Diverted Profits Tax

No Diverted Profits Tax

All Apply

Some Apply (See Notes)

None Apply

C.F.C. Rules

No C.F.C. Rules

Based on O.E.C.D. Rules

Limited Rules

No legislation

Thin Capitalization Rules

Other Rules

No Thin Capitalization Rules

Patent Box

Under Consideration

No Patent Box

Incentives Available

No Incentives (I.P. Box)

No Incentives

Early Adopter

Adopted

Active Participation

Planned Implementation

Model 1

Model 2

REVISED AS OF JUNE 24, 2016 • The above map is limited to the E.U. Member States (and Switzerland) as addressed in “Chapter 274” of the Practising Law Institute's Corporate Tax Practice Series: Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Reorganizations & Restructurings 2016, edited by Louis S. Freeman; www.pli.edu.